Because an ASC that is seeking a Medicare deemed status survey must be open and operational, CMS has advised us to revise our policies regarding the Early Option Survey/Initial Medicare Deemed Status Survey. These policy changes (underlined below) will apply to ASCs that submit an application for an Early Option Survey/Initial Medicare Deemed Status Survey on or after July 1, 2012.

The changes represent updates to policies found in the 2012 Accreditation Handbook Including Medicare Requirements for Ambulatory Surgery Centers (ASCs), page 12:

Types of Surveys

The AAAHC’s early option survey (EOS) is for ASCs that are newly constructed, operational, and actively providing surgical procedures to adequately demonstrate compliance with AAAHC accreditation requirements including Medicare requirements. Some ASCs may require accreditation for third-party reimbursement, and a six-month wait for a survey would entail financial hardship; or they may have been providing services for less than six months and are seeking AAAHC accreditation and Medicare deemed status for the first time.

When an EOS is requested, the ASC must provide evidence of the following with its Application for Survey:

The date the ASC is open and operational and actively providing surgical procedures to adequately demonstrate compliance with AAAHC accreditation requirements including Medicare requirements.

An EOS is conducted during the ninety (90) day survey window on an unannounced basis after the ASC has opened. A minimum of ten medical records must be available for review. The names of the surveyors are not disclosed prior to the survey. The surveyors will observe a surgical procedure during the survey.